I am writing in response to the SEC's proposed regulation to limit the scope of CPA services. I am a managing partner of a local CPA firm with a total staff size of about fifty (50) people, located in the San Francisco financial district. Our firm performs approximately 250 audits each year, as well as providing our clients with tax, consulting and bookkeeping services.

We have found that the additional services that we provide to our clients allow us to obtain more information about the client, its industry, the risks and other situations encountered by our client during the year than we normally obtain in the course of an audit. This additional information leads to better-designed audits and improved disclosure in the financial statements than we would otherwise have.

Our clients also look for help from us when they lose a key financial person. Frequently there is no one left in the client organization who can properly assess the technical capabilities of job applicants for a controller position after the previous controller has resigned, for example. Although we do not make hiring decisions, we have been able to recommend three or four candidates for a position, all of whom meet the technical requirements based on interviews and testing that we perform for the client. The client makes the final hiring decision based on personality and other non-technical factors.

Although we perform no audits under SEC regulations, we fear that your proposed regulations would ultimately filter down to the non-SEC clientele. If other governmental agencies, such as the Department of Labor or the General Accounting Office, harmonized their standards with SEC standards, these regulations would have an impact on the quality of our audits.

We respectfully request that you not place restrictions on our profession's ability to perform services that our clients find us best suited to perform.